Through its rulemaking authority, the Internal Revenue Service (IRS) has identified several types of transactions as “listed transactions.” As the IRS explains, a listed transaction is any transaction that is, “the same as, or substantially similar to, one that the IRS has determined to be a tax avoidance transaction and […]
Category: IRS
Proposed IRS Regulations Would Once Again Enhance Risks Related to Syndicated Conservation Easements
Conservation easements have long served as a tax mitigation tool for high-income taxpayers. They also have a long history of drawing scrutiny from the Internal Revenue Service (IRS). While conservation easements provide a legitimate way for high-income taxpayers to reduce their federal tax burden, they also present significant potential for […]
The Internal Revenue Service (IRS) conducts most audits and reviews remotely. The IRS is responsible for enforcing more than 150 million taxpayers’ obligations, and, as a result, it simply does not have the resources to visit all delinquent taxpayers in person. As a result, receiving an in-person visit from the […]
If you have been contacted by Special Agents from the Internal Revenue Service’s Criminal Investigation division (IRS CI), one of the first questions you need to answer is, “Why?” IRS CI investigates a broad range of both tax-related and non-tax-related offenses, and determining the specific accusations underlying an IRS CI […]
If you’re like most high-income individuals, you rely on an accountant or other tax professional to prepare your federal tax returns. In doing so, you trust that your tax professional will do the right thing, and accurately calculate your tax liability while taking advantage of the various credits, deductions and […]
When companies collect payroll taxes from their employees, they hold their employees’ funds “in trust” pending remittance to the IRS. When companies fail to timely remit their employees’ funds held in trust, they can face substantial liability—including liability for the IRS’ trust fund recovery penalty (TFRP). While the IRS often […]
In 2022, IRS Criminal Investigation (IRS CI) identified $5.7 billion in tax fraud and $26.9 billion in other financial crimes. It executed 1,210 warrants and referred 1,837 cases to the U.S. Department of Justice (DOJ) for prosecution. These referrals resulted in a conviction rate of 90.6 percent. These statistics are […]
According to data cited in a recent NPR article, as much as $64 billion of the $800 billion in forgivable loans issued under the Paycheck Protection Program (PPP) may have gone to applicants that didn’t deserve it. As the article also notes, the federal government has up to 10 years […]
Facing scrutiny from IRS Criminal Investigation (IRS CI) is a serious matter. As its name suggests, IRS CI is tasked with uncovering—and assisting in the prosecution of—criminal violations of the Internal Revenue Code (IRC). But, IRS CI’s investigative authority also extends far beyond the IRC, and it routinely announces investigations […]
Under the Internal Revenue Code (IRC), interest on unpaid taxes begins to accrue immediately. When taxpayers incur penalties for failure to pay or failure to file, these penalties begin to accrue interest promptly as well. New Underpayment Interest Rates for Federal Taxes and Penalties (Effective January 1, 2023) The Internal […]